OIG coinsurance advisory opinion limited in scope
OIG coinsurance advisory opinion limited in scope
The Department of Health and Human Service’s Advisory Opinion on waiver of co-insurance released July 10 gives the requesting hospital the green light. However, Dan Mulholland, a partner with Horty Springer in Pittsburgh, says the hospital’s unique circumstances limit the opinion’s applicability.
Under the scenario presented, one hospital sought to accept reimbursement from third-party payers, plus certain payments from a hospital foundation as payment in full, without regard to a patient’s financial need.
The Office of Inspector General (OIG) rebutted the hospital’s argument that the Insurance-Only Billing Policy doesn’t result in waivers of coinsurance because the foundation pays the uncollected coinsurance on behalf of patients. "Given the close relationship between Hospital A and the Foundation — their overlapping boards, their joint annual statement, the foundation’s specific charitable mission — the foundation payments simply move money from one Hospital A pocket to another, and the coinsurance is effectively waived," asserted the OIG.
While this practice could potentially generate prohibited remuneration under the anti-kickback statute, the OIG said that it would not impose administrative sanctions.
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